sanofi-aventis australia pty ltd trading as Sanofi Genzyme, (hereinafter “Sanofi Genzyme”) are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) for Australia as well as the Privacy Principles contained in the Privacy Act 1993 for New Zealand (together referred to as the “Principles”). The Principles define personal information as information or an opinion relating to an individual which can be used to identify that individual (such as name, address, telephone number, email address), and are designed to protect the confidentiality of personal information and the privacy of individuals by regulating the way personal information is managed.
1. Why does Sanofi Genzyme collect personal information?
Sanofi Genzyme is a leading Australian company and is part of the international Sanofi Genzyme Group. Sanofi Genzyme is in the business of researching, developing, manufacturing and marketing pharmaceutical and rare disease products. As a matter of conducting its routine business, Sanofi Genzyme may collect the following types of personal information:
When you look at a Sanofi Genzyme operated website, the Internet Service Provider of our parent company located in France makes a record of your visit and logs the following information for statistical purposes:
- your server address;
- your top level domain name (for example .com, .gov, .au, .uk etc);
- the pages you accessed and documents downloaded;
- the previous site you have visited; and
- the type of browser you are using.
Sanofi Genzyme will only record your e-mail address if you send us a message. Your e-mail address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent.
Google Analytics Demographics and Interest Reporting have been enabled on some Sanofi Genzyme operated websites and as a result personal information about users such as age, gender and interests may be collected. Such information will only be used or disclosed for the purpose of better understanding our users in order to identify how experience and interaction can be improved and tailoring the information which is provided to them. This personal information will not be used or disclosed for any other purpose without your consent.
2. How does Sanofi Genzyme use personal information and to whom may Sanofi Genzyme disclose it?
The Principles generally require Sanofi Genzyme to use personal information only for the primary purpose for which it is collected, or for secondary purposes that are related to the primary purpose.
This may include the use of third party software to store, collate and manage your personal information. The third party entities do not have direct access to your personal information. Your personal information will only be used for direct marketing with your consent. You are able to “unsubscribe” from the mailing list and the direct marketing communications at any time by contacting our Privacy Officer. Sanofi Genzyme’s websites are managed by an external agency, so your personal information will also be disclosed to an external agency to assist with this purpose.
Your data will be retained by the marketing automation platform for the specific purpose of providing you with tailored communication in accordance with your preferences. This data will be stored and accessed solely for this purpose.
In general, Sanofi Genzyme uses personal information for the following purposes to:
- Promote and market Sanofi Genzyme’s products and services;
- to provide health products or services (including advice) that have been requested;
- to involve doctors and investigators (and the people who assist them) in clinical trials; and
- To comply with legal obligations.
Sanofi Genzyme discloses personal information to third parties, including its associated Companies, within or outside of Australia or New Zealand, including but not limited to: France, USA, Singapore and Japan to help Sanofi Genzyme improve its pharmaceutical, consumer healthcare, rare disease, vaccine and animal health products and health services. Information may also be disclosed to regulatory authorities and ethics committees as part of a clinical trial evaluation, monitoring or inspection process. Sanofi Genzyme will also disclose personal information to its Affiliate in Malaysia for the purposes of processing invoices and accounts.
Generally, we require that organisations outside Sanofi Genzyme who handle or obtain personal information as service providers to Sanofi Genzyme acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with the Principles and this Policy.
In most cases, if you do not provide information about yourself which Sanofi Genzyme has requested, Sanofi Genzyme may not be able to provide you with the relevant service or information required.
3. Sensitive information is subject to greater restrictions
Some personal information collected by Sanofi Genzyme is considered “sensitive”. Sensitive information which Sanofi Genzyme may collect includes a person’s state of health and medical history.
The Principles require that sensitive information is used and disclosed only for the purposes for which it was provided, or a directly related secondary purpose, unless you agree otherwise or for other specific reasons such as if the use or disclosure of this information is required by law or to prevent a serious and imminent threat to life or health of an individual.
Sanofi Genzyme’s interactions with you are also regulated by the Spam Act 2003 in Australia and the Unsolicited Electronic Messages Act 2007 in New Zealand. In compliance with these Acts, Sanofi Genzyme will not send you a commercial electronic message to you unless permitted.
5. Management and security of personal information
SanofiGenzyme has appointed a Privacy Officer to oversee Sanofi Genzyme’s management of personal information in accordance with this Policy and the Principles.
All data that is collected is held electronically on password protected systems. Personal information is only accessible by persons that require access to that information to carry out their work. Sanofi Genzyme has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure from unauthorised access or disclosure.
6. Accessing personal information that Sanofi Genzyme holds about you
You can, in most cases, access the personal information Sanofi Genzyme holds about you. If you wish to do so, please contact Sanofi Genzyme as set out below.
7. Updating personal information that Sanofi Genzyme holds about you
Sanofi Genzyme endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. Please contact Sanofi Genzyme if you believe that the information Sanofi Genzyme holds about you requires changing or becomes out-of-date. Sanofi Genzyme’s contact details are set out below.
8. What if you have an enquiry?
9. How to complain about a privacy breach and how will Sanofi Genzyme deal with such a complaint?
If you believe that Sanofi Genzyme has breached the Principles you may complain in writing to our Privacy Officer (see contact details below). Sanofi Genzyme will respond within thirty (30) days and will use its best endeavour to resolve the issue.
If you are unsatisfied with Sanofi Genzyme’s answer, you may take your complaint to the Office of the Australian Information Commissioner as detailed on http://www.oaic.gov.au/privacy/privacy-complaints or to the Office of the Privacy Commissioner for New Zealand as detailed on http://www.privacy.org.nz/your-privacy/how-to-complain/.
How to contact us for requests for Sanofi Genzyme in Australia and New Zealand
Sanofi-aventis Australia Pty Ltd
Talavera Corporate Centre
Building D, 12-24 Talavera Road
Macquarie Park NSW 2113
This Policy is effective from 1 February, 2014